82nd ITALIAN OPEN
Argentario Golf Club 26 – 29 June 2025

PRIVACY POLICY pursuant to Articles 13 and 14 of Regulation (EU) 2016/679
(hereinafter "GDPR")

Dear Sir/Madam,
We inform you that Golfed Srl (Golfed), with registered office in Rome, Viale Tiziano n. 74, VAT no. 15660321009, a single member company subject to the direction and coordination of the Italian Golf Federation, in its capacity as the Data Controller, will process - for the purposes and in the manner described below - the personal data you provide when registering on the portal https://accrediti.openditaliagolf.eu/ for access to the 82nd Italian Open (hereinafter also ‘Event’) or otherwise acquired during the course of the recalled Event. In case of participation of minors, the relevant personal data will be processed, including following the provision by parents or those exercising parental responsibility (pursuant to Article 8 of the GDPR).

Specifically, Golfed will process the following data:

a) personal and identification data (name and surname, date and place of birth, residence, telephone and email contacts)
b) images and video footage acquired during the course of the Event and related activities;

1. Legal basis and purpose of the processing.

1.1 The processing of the data referred to in (a) is based on Article 6(1)(b), (c) and (f) of the GDPR and is aimed at managing participation in the event and fulfilling administrative, legal and accounting obligations required by national (including sports, statutory and federal provisions), European and international regulations, as well as sending materials and information related to the event or its future editions.
1.2 The processing of data referred to in b) is based on Article 6(1)(f) of the GDPR and is aimed at the production of video footage and photographs relating to the event indicated in the foreword, as well as their subsequent dissemination through various means of communication, such as, but not limited to, the institutional website, magazines, newspapers, television stations, the Internet, brochures and social media.
1.3 The processing of the data referred to in letter a) is also based on your consent and is aimed at remaining in contact with the writer and/or the Italian Golf Federation (FIG), with which the aforementioned data will be shared, through the sending of printed material, dedicated e-mails and newsletters promoting golf sports through institutional and commercial activities.
1.4 The processing of the data referred to in lett. a) is also based on your consent and is aimed at sharing your data with Infront Italy S.p.A., “Commercial Advisor of the Italian Golf Federation”, for promotion of sports events and for commercial purposes.

2. Method of processing

The processing of your personal data is carried out with the aid of electronic means, by means of the operations indicated in art. 4 n.2) of the GDPR and precisely: the processing of your personal data may consist of the collection, recording, organisation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.

3. Obligation to provide data

3.1 The provision of data for the purposes set out in point 1.1) and 1.2) is strictly necessary for the management of the Event indicated. Any refusal will result in the impossibility of accessing the Event.
3.2 The provision of data for the purposes referred to in points 1.3) and 1.4) is optional.

4. Scope of data communication

The following may become aware of your data:
- the staff of Golfed srl specifically appointed and other volunteers specifically appointed to process the data;
- the Italian Golf Federation;
- Infront Italy S.p.A.;
- DP World Tour ;
- the IT companies involved in the management of the IT infrastructure, of the website as Data Processors.

5. Transfer of data abroad.

5.1 Personal data are stored on servers located in Italy. It is in any case understood that the Data Controller, if necessary, will have the right to move the servers outside the EU. In this case, the Data Controller assures as of now that the transfer of data outside the EU will take place in compliance with the applicable legal provisions and in particular those of Title V of the GDPR.
5.2 Apart from the cases referred to in Article 5.1. and 5.3. below, your data will not be transferred outside the EU.
5.3 For the purposes indicated, your data - or some of them - may be communicated to: a) suppliers; b) other subjects to whom the right to access personal data is recognized by provisions of law or regulation. These subjects, with regard to processing carried out on behalf of the Data Controller in relation to activities outsourced by the same, will operate as “external data controllers” pursuant to Article 28 of the GDPR. Please be advised that such entities may transfer your personal data outside the European Union: in this case, the Data Controller will ensure that such activity is carried out in compliance with the conditions set out in the GDPR and, in particular, Articles 45 et seq. With strict reference to point 1.4 herein, in view of Infront Italy S.p.A.'s belonging to an international group and the existence of telematic, computer and correspondence links in general between the various companies of the group, some personal data will be transferred, for the purposes set out in this information notice, to such companies also in countries outside the European Union (more specifically in Switzerland). With regard to Switzerland, we inform you that the European Commission, by Decision No. 2000/518/EC of July 26, 2000, has recognized that this country guarantees an adequate level of protection of personal data.

6. Period of data retention

6.1 The data will be retained for a period of 1 year from the end of the Event.
6.2 Verification of the obsolescence of the data being processed with respect to the purposes for which they were collected and processed is carried out periodically.

7. Data controller

Golfed Srl, Viale Tiziano, 74 in Rome - privacy@federgolf.it

8. Rights of the interested party

You will have the right at any time to know the data concerning you, to know how it was acquired, to check whether it is accurate, complete, up-to-date and well kept, and to request its rectification or deletion in accordance with Articles 16 and 17 GDPR. You will also have the right to receive the personal data provided by you and processed with your consent, in a structured, commonly used and machine-readable format, and to revoke at any time any consent you may have given regarding the processing of your data. Pursuant to Article 21 GDPR, you will have the right to object, in whole or in part, to the processing of data for reasons related to your particular situation. These rights may be exercised through specific application to be addressed by registered letter to the Data Controller. You also have the right to lodge a complaint with the Data Protection Authority.

Rome, 4 June 2025
The Data Controller
Golfed Srl